- 27 -
See Solomon v. Commissioner, 732 F.2d 1459, 1461 (6th Cir.
1984), affg. per curiam T.C. Memo. 1982-603. A taxpayer's
intelligence, education, and tax expertise are also
relevant for purposes of determining fraudulent intent.
See Stephenson v. Commissioner, 79 T.C. 995, 1006 (1982),
affd. 748 F.2d 331 (6th Cir. 1984); Iley v. Commissioner,
19 T.C. 631, 635 (1952).
Respondent contends that the following facts, taken
as a whole, establish that the entire underpayment of tax
for 1983 was attributable to fraud: (1) The unreported
income was derived from an illegal activity; (2) petitioner
failed to maintain or produce adequate records of his drug
smuggling income; (3) he dealt exclusively in cash; (4) he
never informed his return preparer of his income from the
illegal activity; (5) he made inconsistent statements
regarding the amount of money he earned from the activity;
(6) there is a large discrepancy between petitioner's
actual income and the income reported on his return;
and (7) petitioner structured his bank deposits in such
a manner as to avoid the filing of Currency Transaction
Report forms with the Internal Revenue Service.
We agree with respondent. Petitioner failed to report
a very large portion of his income for 1983 in an attempt
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